JUDGMENT

(Prayer: Appeal filed under Clause 15 of Letters Patent against the order dated 11.06.2021 passed in WP No. 22901 of 2010 on the file of this Court.)

R. Mahadevan, J.

Aggrieved by the order of dismissal dated 11.06.2021 passed by the learned Judge in WP.No. 22901 of 2010, the present intra-court appeal has been filed by the appellant / writ petitioner.

Facts.

2. The case projected by the appellant in the writ petition would run thus:

2.1. The appellant is engaged in the business of software development and they render services to its wholly owned subsidiaries outside India, City Group entities and also unrelated third party customers. For the assessment year 2006-2007, they submitted their return on 30.11.2006 declaring the total income of Rs.9,26,58,233/-, which was assessed by the Assessing Officer under Section 143 (1) of The INCOME TAX ACT (in short, “the Act”) on 14.03.2008 and a refund of Rs.4,86,96,384/- was issued on 28.03.2008.

2.2. Subsequently, pursuant to the proceedings of the Commissioner of Income Tax, Chennai, dated 25.08.2008, the third respondent issued a fresh notice under Section 143 (2) on 04.09.2008 to the appellant. In response to the same, the representat